Thank you for your interest in our Group. Data protection is important
process personal data, i.e. data concerning an identified or
identifiable natural person, such as name, address, nationality, e-mail
address, interests and hobbies, user behaviour on websites. This privacy
policy is based on the EU General Data Protection Regulation (GDPR).
1 Controller, data protection officer and representative
(1) First Advisory Trust reg., Wuhrstrasse 6, Vaduz, is the controller under data protection law.
(2) The contact details of the data protection officer are as follows:
Telephone: +423 236 30 00
2 Collection of personal data and purposes of the processing
We limit the processing of personal data primarily to data which we
receive in connection with our products and services from our customers,
our cooperation partners or other parties involved, or which we collect
from users on our websites, apps and other applications.
(2) In particular, we collect the following personal data from you, based on the specific purpose (see below):
- First name, last name
- e-mail address
- Telephone number(s)
- Date of birth
- Hobbies / personal interests
- Family relationships
- Tax identification number
- Bank details
If permitted and appropriate, we also obtain and process other
specifically relevant data from publicly accessible sources (e.g. land
register, trade register, media, internet, World-Check) or receive this
data from other group companies, authorities and institutions and your
personal environment such as family and legal advisor or from third
(4) We need the data mainly for the following purposes:
- To identify you as a customer, cooperation partner or user of our website
- To correspond with you
- To comply with our duty of care
- To comply with other legal regulations
- To enter into and process service agreements, e.g. incorporation order, mandate agreements, license agreements
enter into and process purchase and sale contracts, e.g. for purchase
of products from suppliers or sale to prospective customers
- To invoice
- To provide other services from our organisation or in cooperation with third parties when appropriate
- To provide the best possible customised services to you and to further develop our range of products and services
- To communicate with third parties
- To assess and respond to applications
- To promote and market our products and services (unless you have raised an objection to this use of your data)
- To assert legal claims or defend our position in general
- To safeguard our business in general (e.g. IT, websites, apps)
- To use CCTV as a security element for access management (including visitor lists or other access controls)
- To maintain other security aspects
We only process your personal data if we have a legal or contractual
basis for doing so or if processing of the data is necessary to perform a
duty which is in the public interest or is exercised under public
authority. Otherwise we only process data if we have your permission and
no refusal exists, or if a legitimate interest of our own is overriding
(e.g. continued delivery of newsletters to existing customers, again
only if no refusal exists). Permission may be withdrawn at any time.
3 Recipients of personal data and international data transfer
We only transmit your personal data to recipients or third parties in
connection with the purposes described above, if permitted and
appropriate. They may particularly include:
- Group companies
- Service providers such as banks, asset management companies, insurance companies, IT providers, print shops
- Customers of ours
- Suppliers, dealers, transport companies, subcontractors or other cooperative partners
- Authorities, state institutions, courts
- Societies, public interest institutions
This type of data transmission is based on a legal obligation (e.g.
data transfer under the Automatic Exchange of Information), performance
of a contract (e.g. foreign asset manager), permission by you, a public
interest or a legitimate interest of our own, unless your interests or
fundamental rights and freedoms in respect of protection of personal
data are overriding.
(3) Recipients may be in this country or
abroad. Your attention is drawn in particular to the fact that we may
exchange personal data within our group companies or transmit personal
data to countries where service companies from which we obtain services
(e.g. Microsoft, Thomson Reuters) are located.
If recipients outside
our company are located in the EU/EEA or in countries with recognised
data protection adequacy (e.g. Switzerland), we ensure data protection
by entering into an outsourced data processing agreement – if necessary
If we transfer personal data to third party
countries without adequate legal data protection, we ensure an adequate
level of protection in accordance with legal requirements, for example,
on the basis of standard EU contract clauses or other instruments (e.g.
binding corporate rules, US privacy shield).
4 Use of our website(s)
addition to the above, we inform you when you use our websites about
(1) If your use of the website is purely for information
(i.e. you do not log in, register or provide us with other information
to use the website) we do not collect any personal data with the
exception of data communicated by your browser to enable you to visit
the website, which may include the following specific data:
- IP address
- Date and time of inquiry
- Time zone difference from Greenwich Mean Time (GMT)
- Content of request (actual webpage)
- Access status/HTTP status code
- Data volume transferred
- Website from which the request comes
- Browser used
- Operating system and its interface
- Browser software language and version
Our website uses ‘cookies’. These are small text files that are placed
on your device through the browser. Cookies are not harmful.
use them to make our offering more user friendly. Some cookies remain
stored on your device until you delete them. They allow us to recognise
your browser when you next visit.
If you do not want this, you can
set your browser to let you know if cookies are placed and only allow
this in exceptional cases. We must point out that in this case you may
not be able to use all the functions on our websites fully.
We use Google Analytics on our websites. Google Analytics is a web
Web analytics means the collection, compilation and analysis of data on
visitor website behaviour. Among other things, a web analytics service
generates data on the website from which a particular person has reached
a website, which subpages of the site have been accessed or how often
and for how long a subpage has been viewed. Web analytics are mainly
used to optimize a website and for cost-benefit analysis of online
The purpose of Google Analytics is to analyse visitor
numbers on our website. Google’s use of the data and information
obtained includes analysis of the use of our website to compile online
reports for us which indicate the activity on our website and provision
of other services associated with use of our sites. Google may combine
your behaviour with other websites visited by you. If you are a
registered Google account holder, Google will recognise you. The Google
data protection regulations will then apply to further processing of
personal data. Using the cookies, personal information such as access
time, place from which access originated and frequency of visits to our
website by the person concerned will be stored. On every visit to our
websites, the personal data, including the IP address of the internet
connection used by the person concerned, will be transmitted to Google
in the USA. Google may also transmit the personal data collected via the
technical process to third parties.
As described above, the person
concerned can prevent cookies being placed through our website at any
time by selecting the appropriate settings on the browser used and
permanently refusing their use. Setting the browser in this way can also
prevent Google placing a cookie on your device (e.g. computer,
notebook, tablet). A cookie already placed by Google Analytics can also
be deleted at any time via the browser or other software programs.
For more information please contact Google directly, on the following links:
We use Google AdWords on our websites. Google AdWords is an online
advertising service which allows advertisers to place ads in both the
Google search engine results and the Google advertising network. Google
AdWords enables an advertiser to predefine specific key words by which
an ad is then only displayed in the Google search engine results if the
user uses the search engine to access a search relevant to the key word.
In the Google advertising network the ads are distributed across
subject relevant websites by means of an automatic algorithm and by
recognising the predefined key words.
The purpose of Google AdWords
is to promote our website by insertion of interest based advertising on
the websites of third companies and in the Google search engine results,
and insertion of external advertising on our website.
If a person
accesses our website via a Google ad, Google places a conversion cookie
on that person’s IT system. We have explained above what cookies are. A
conversion cookie ceases to apply after thirty days and is not used to
identify the person concerned. If the conversion cookie has not yet
expired, it is used to track whether specific subpages, such as the
basket of an online shopping system, have been accessed on our website.
Through the conversion cookies both we and Google can track whether
someone who accesses our website via an AdWords ad has generated a sale,
i.e. has completed or discontinued a purchase.
The data and
information collected via the conversion cookie is used by Google to
produce visitor statistics for our website. We then use these statistics
to determine the total number of users routed to us via AdWords ads and
therefore the success or failure of each AdWords ad, and to optimise
our AdWords ads for the future. Neither our company nor other
advertising customers of Google AdWords receive information from Google
which could identify the person concerned.
Personal information such
as the websites visited by the person concerned is stored by the
conversion cookie. Whenever our websites are visited, personal data,
including the IP address of the internet connection used by that person,
is transmitted to Google in the United States of America. The personal
data is then stored by Google in the USA. Google may also transmit the
personal data collected via the technical process to third parties.
described above, the person concerned can prevent cookies being placed
through our website at any time by selecting the appropriate settings on
the browser used and permanently refusing their use. Setting the
browser in this way can also prevent Google placing a cookie on your
device (e.g. computer, notebook, tablet). A cookie already placed by
Google Analytics can also be deleted at any time via the browser or
other software programs.
The person concerned also has the option of
refusing interest based advertising by Google. To do this, the person
must go to the link www.google.de/settings/ads from each of the internet
browsers he uses and then enter the required settings.
5 Data protection in applications and application processes
collect and process personal data from applicants in order to progress
the application process. The processing may be on paper or
electronically by e-mail or by completing an online form. If a contract
of employment is concluded with an applicant, the personal data received
is processed to administer the employment, in accordance with the legal
regulations. Otherwise the application documents are deleted three
months after rejection, unless deletion is contrary to legitimate
interests of our own, for example in connection with a burden of proof
in relation to equal treatment. If you give permission, we can keep
application documents for a longer period so that they can be considered
for any subsequent vacancy.
6 Storage period
keep your personal data for as long as necessary for the purposes for
case that we are obliged by law to store specific data for a longer
period. In this case we make sure that your personal data is handled for
7 Your rights
You have the right to ask us free of charge at any time about the
personal data that we hold about you and its origin, the recipients or
categories of recipients to whom the personal data is transferred and
the purpose of its storage.
(2) You also have the right to ask us at
any time for rectification, deletion or restriction of the processing of
your personal data. You also have the right to data portability.
(3) You also have the right at any time to refuse to allow us to process your personal data.
(4) If you have given us permission to use personal data, you may withdraw this at any time without giving reasons.
(5) If you wish to exercise the above rights, please contact the address given in paragraph 1.
8 Data security
maintain the latest technical facilities to guarantee data security and
in particular to protect your personal data against risks in data
transfers and from disclosure to third parties. These facilities are
always upgraded to the state of the art.
As part of
the technical development of our service offering and within the legal
to the policy will be published on our website. Please read the current
force as soon as the updated policy is published.
Vaduz, May 2018